Archive for the ‘Air Pollution’ Category

We’re urging Brighton & Hove City Council to refuse permission for the Toads Hole Valley development when it is reconsidered on 25 May, 2022, due to it undermining key local and national targets. This is the city’s biggest greenfield site and was meant to be an exemplar of sustainable development. Instead it is a shining example of everything that is wrong with transport planning: the development will unnecessarily increase traffic, congestion and pollution within the city.

The city has the ambition to be net-zero by 2030, supported by both Labour and the Greens, yet this development will undermine that. It will increase emissions from transport, when it is likely we will need to reduce traffic in the city by around 25 – 50% to meet this target.

The proposed bus service is inadequate, even before concerns that the money set aside for it will remain sufficient due to rapidly rising inflation. There are also no safe cycle facilities connecting the development with the city, and their future development is prejudiced by the main junction design.

The Travel Plan for the site is set to lock in polluting travel behaviour. Its level of ambition so poor, that it will undermine the Government target for over a half of all journeys in urban areas to be walked and cycled by 2030. Nearly one quarter of all the homes in the first phase will have no access to public transport or cycle infrastructure except into the National Park. This will lock them into car-based lifestyles. The rest of the development will fare little better.

Chris Todd of BHFOE said:

“The usual obsession with modelling traffic levels, without first aiming to maximise a reduction in car use has resulted in the all too familiar results: rising traffic, increased pollution and congestion, and scarce resources being wasted on building bigger junctions. We need a different approach.

“How can a development in the 21st century have no cycle links into the city and not come with a high frequency bus service? The fact that the highways authority appears to have completely ignored these issues is even more worrying. It provides bland reassurances that further improvements can be sought later on, but the junction design for the main entrance will prejudice links to Nevill Road and elsewhere.

“The Travel Plan, while containing an impressive list of actions, is effectively admitting failure with its very weak targets and expectation of huge car dependency. While it will encourage new residents to reduce car use when they move in, they can only do that if there are safe and attractive options. Nearly a quarter of the residents won’t have access to any cycle or bus links into the city when they move in, while the rest will only have access to an inadequate bus service.

“For people to even consider calling this an exemplary sustainable development is beyond belief. It is a massive wasted opportunity which will cause great harm to the city with more traffic and pollution. What is most shocking is that the lack of scrutiny of transport issues has left the Planning Committee in the dark. This will have skewed their conclusions last time and could skew them again. The development should be rejected until these critical issues are resolved.”


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We’re disappointed with Adur District Council’s decision to approve the New Monks Farm development, which in turn will see the closure of the Sussex Pad crossing. But our campaign is far from over.

We still have a chance to save the Sussex Pad – or getting a better replacement – by asking the Government to review the council’s decision.

Can you spare 5 minutes to send a letter and help keep the campaign going?

Ask the Government to save the Sussex Pad

At the start

Please share with family, friends and colleagues and encourage them to act to.

Many thanks

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local campaigners at Brighton clock tower

local campaigners at Brighton clock tower

The other week the consultation ended on the City Council’s draft Air Quality Action Plan. This will be an important document what with the recent Supreme Court Judgment (on 29 April) which has ordered the Government to draw up a new national Action Plan to bring air pollution down to within legal limits ‘as soon as possible’. What exactly that means is debatable, but recent rulings in the European Court suggest that difficulty and cost are not reasons for delay.

Yet why would anyone want to delay? The problem is deadly serious with over 29,000 premature deaths every year attributable to air pollution, ten times the number killed in road crashes, and the second deadliest killer in the UK after smoking. Even this is likely to be a serious underestimate as it only looks at the impact from particulates (tiny particles of black soot). It does not include any estimate of the impact of nitrogen oxides and other pollutants. At a local level, that equates to 115 people a year, more than die through alcohol poisoning or drug overdoses where it seems more public funding and effort are spent tackling these issues. Certainly there is greater awareness.  In contrast, little is spent tackling the root causes of air pollution, which in Brighton & Hove is predominantly traffic, with no focus on traffic reduction.

We have responded to the consultation and welcomed much of the analysis in the report and its commentary. However, where we have struggled is with some of the proposed actions. More car parking and road building should be the actions of last resort, yet these are fairly high up on the list. They will only bring short term relief and most likely make the situation worse within a year or two.

The report is big on evidencing the problem and identifying where interventions can be targeted to have most impact. Yet the same rigour is not applied to potential solutions. A park and ride site on greenfield land near Preston Barracks is likely to create more pollution in the Lewes Road corridor. In addition, if we are to build on a green field it should be for housing and in this location could be virtually car-free.

Recently, we also responded to a further consultation on the City Plan modifications (the document which creates the blueprint for development in the city over the next 10-15 years). In our submissions, we requested the Inspector revisited the wording around air pollution to ensure it conforms with the recent Court rulings. We want there to be a requirement that developments do not delay air pollution being brought down to safe levels as soon as possible.

What we want to see is national Government shift funding away from road building into low emission buses, to tackle this issue in many of our cities. At a stroke, that would make a vast improvement and could be done within a few years. Secondly, we want the Council to focus much more on getting more people walking, cycling and using public transport. One reason why the Valley Gardens scheme is so important, but also why action needs to extend further than this. As part of this process we need to see joined up thinking with planning across Government and action taken to promote more car-free development and have development focussed around alternatives to the car. Unfortunately, the Government seems hell bent on removing local autonomy around planning, apart from on wind turbines, despite its so-called localism agenda, which has been anything but.

Alongside all of this, and this is certainly something local government can do, we need some serious awareness raising with the public so that they understand what the issues are and why we need to tackle this invisible killer.

Only then, can we afford to breathe easy.

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Group criticises draft planning document

Brighton & Hove Friends of the Earth (BHFOE) has submitted a critical response to Brighton & Hove City Council’s consultation on its draft Parking Supplementary Planning Document (SPD), which ended on 27 March.

BHFOE is concerned that if the SPD is adopted as it is currently drafted it could lead to the long term increase of cars in the city, creating more congestion and pollution, delaying bus services and harming the local economy.  It believes that the SPD may not be lawful if it leads to an increase in air pollution and delays the time that areas already above the legal limits take to become compliant [1].  It is also concerned at the unintended consequences of the standards which could see the loss of front and back gardens for parking when properties are redeveloped and the loss of historic streetscapes.

Chris Todd, planning and transport campaigner for BHFOE said:

“While we fully support the need for local parking standards what is currently proposed could be highly damaging.  It could lead to the loss of green space within the city as front and back gardens are tarmacked over to provide parking.  This would be detrimental for residents and would also harm the city’s historic streetscapes.

“Overall it will increase the number of cars in the city which will only mean more congestion and pollution.  This is at a time when more and more evidence is emerging about the harm that air pollution is causing.  The UK has an obligation to reduce air pollution to below legal limits as soon as possible.

“All new development within the city centre needs to be ‘car-free’ so that it improves the current situation, not makes it worse.  Allowing development which will bring more cars into our strategic bus corridors in the heart of the city is madness.  In the long term it could bring the city to a grinding halt and seriously damage the local economy.”

[1]        Large parts of the city centre are within an Air Quality Management Area and have nitrogen dioxide levels above legal limits.  The worst areas are around North St, Western Road and the Clock Tower.  The UK has already missed the deadline that it was mean to have met to reduce air pollution to safe levels by and recently lost a European Court Case due to its lack of action to tackle this serious issue which leads to at least 29,000 premature deaths every year in the UK.  It is estimated that 115 people a year die prematurely in Brighton & Hove due to particulate pollution, although the number who die prematurely due to all air pollution will be higher.

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We have responded to the consultation on the proposed modifications to the City Plan, which ended at midnight on 16 December. While we support much of what is proposed we have issues with three main areas:

Air pollution:  despite agreeing with the Council to proposed modifications on this issue earlier in the year, recent events (European Court Ruling and emerging research) mean that the proposed wording may be unsound as it does not go far enough to reduce air pollution and act to bring it down below legal limits as fast as possible.  In fact developments could still be approved that will make it worse.

Urban Fringe development:  we have pointed out errors in the Urban Fringe Assessment which undermine the figures for housing in the urban fringe.  We have therefore questioned whether it is justified to have an allocation of 1,060 homes in the urban fringe.

Watering down of energy efficiency:  we have objected to the watering down or energy requirements in new development, not least because as a city we have consistently missed our carbon reduction targets and need urgent action to bring us back on course.  Indeed the fact that we’ve missed our targets year on year, means that we have emitted more carbon than we should and so need to cut our levels even more to compensate.

To see our full comments and links to references, see our submission.

The examiner will now look through all responses to the consultation and see whether any areas warrant further investigation or debate before deciding whether to accept that the City Plan is sound and can be adopted.  The is an important moment for the Council as without a agreed Plan it is in a very weak place to prevent damaging developments.

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